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“unexplained investment”

Cash Credits & Unexplained ItemsSection 69Section 695,821 judgments

The decision most relied on for unexplained investment is Sumati Dayal v. CIT (214 ITR 801), cited in 1,967 judgments on BharatTax.

Leading authorities on unexplained investment

Sumati Dayal v. CIT
214 ITR 801 · 1995 · Supreme Court
1,967
citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

K.P. Varghese v. ITO
131 ITR 597 · 1981 · Supreme Court
989
citing judgments

An addition to income cannot be made merely on the basis of a difference in valuation of assets or a Valuation Officer's report without establishing actual understatement of consideration or the source of unexplained funds through proper enquiry. The Assessing Officer must conduct proper enquiry and satisfy the conditions for making such additions.

Chuharmal v. CIT
172 ITR 250 · 1988 · Supreme Court
340
citing judgments

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

CIT v. Kamdhenu Steel & Alloys Ltd.
361 ITR 220 · 2014 · High Court
328
citing judgments

When making an addition under section 68, the creditworthiness or financial strength of an investor contributing share capital or share application money can be proved by producing their bank statements showing sufficient balance for the investment. The Supreme Court dismissed the SLP against this decision.

CIT v. Dwarkadhish Investment (P) Ltd.
330 ITR 298 · 2011 · High Court
218
citing judgments

An assessee cannot be asked to explain the source of the source for cash credits, particularly share capital or share application money, once they have discharged the initial onus regarding the identity, genuineness of the transaction, and creditworthiness of the immediate investor.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.
56 Taxmann.com 286 · 2015 · High Court
196
citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional evidence.

ITO v. Ch. Atchaiah
218 ITR 239 · 1996 · Supreme Court
149
citing judgments

Under the Income-tax Act, 1961, the Assessing Officer must tax any taxable income in the hands of the correct assessee to whom it truly belongs, having no option to assess it in any other person's hands.

CIT v. Stellar Investment Ltd.
192 ITR 287 · 1991 · High Court
146
citing judgments

Once the identity of the shareholders is established, no addition can be made in the hands of the assessee company under Section 68 for share capital or share application money, as it cannot be treated as undisclosed income.

Judgments citing unexplained investment

Shri Atma Ram, Nakodar vs. Income Tax Offiecer Ward, Nakodar

In the result, the appeal of the assesse is allowed for statistical

ITA 141/ASR/2023[2017-18]Status: DisposedITAT Amritsar04 Aug 2023AY 2017-18

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Rakesh Joshi, AdvFor Respondent: Sh. Mohit Kumar Nigam, Sr. DR
Section 144Section 69A

evidence against the assesses, merely on surmises and conjectures, sale of own tractor of the appellant could not have been characterized/ replaced with alleged unexplained investment u/s 69A. 5. It is seen that the Ld. CIT(A) has confirmed the addition by observing that the A.O. has made detailed discussion

Vikesh Chaturbhuj Agrawal, Nagpur vs. ITO-Ward-4(1), Nagpur

In the result, the appeal filed by the assessee stands dismissed

ITA 408/NAG/2013[2008-09]Status: DisposedITAT Nagpur04 Aug 2023AY 2008-09

Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI S. S. VISWANETHRA RAVI (Judicial Member)

For Appellant: Shri Nilesh SindhwaniFor Respondent: Smt. Rashmi Mathur
Section 143(3)

kilometres from the Municipal Corporation of Nagpur and the lands being agricultural are exempt from tax. As regards, the addition made on account of unexplained investments in respect of purchase of land from one Mr. Akone at Khadka, the ld. CIT(A) confirmed the addition rejecting the contention ... rival submissions and perused the material on record. The issue in the present appeal relates to the addition of Rs.12,75,000/- as unexplained investments in purchase of land at Khadka. The Assessing Officer had examined the seller of the land, who was stated to have denied the receipt

Suresh Sharma, Raipur vs. Assistant Commissioner of Income Tax-1(1), Raipur

In the result, appeal of the assessee is partly allowed for statistical purposes in terms of our aforesaid observations

ITA 36/RPR/2023[2014-15]Status: DisposedITAT Raipur04 Aug 2023AY 2014-15

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 36/Rpr/2023 "नधा"रण वष" / Assessment Year : 2014-15

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 131Section 133ASection 143(2)Section 143(3)

unaccounted income for carrying the business outside his books of accounts on an estimate basis made an addition of Rs. 25 lac towards such unexplained investment. Although the AO had rejected the books of account of the assessee but he thereafter after referring to individual head of expenses made certain

M/S. Worldwide Fourtune Homes, Kathua vs. Deputy Commissioner of Income Tax Central Circle, Jammu

In the result, appeal of the assessee ITA No

ITA 197/ASR/2023[2018-19]Status: DisposedITAT Amritsar03 Aug 2023AY 2018-19

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 133ASection 143(3)Section 250Section 250(6)Section 292CSection 69A

High Court of Madras in the case of Thiru S. Shyam Kumar vs. ACIT reported at [2018] 99 taxmann.com 39 has held as under: “Unexplained investment (On-money payment) - A search was conducted in business premises of assessee wherein certain loose slips were recovered, which showed several entries pertaining

Sampat Lal Lodha, Nathdwara vs. ITO, Ward-2, Rajsamand

In the result, both appeals of the assessee are allowed

ITA 2/JODH/2022[2011-12]Status: DisposedITAT Jodhpur02 Aug 2023AY 2011-12
Section 143(1)Section 147Section 68

Date of Judgement/Order : 03/12/2021, held as under: - “The principles governing cash credit under Section 68 of the Act cannot be extended to unexplained investments under Section 69A of the Act.” iii] In view of above the reasons for reopening assigned and addition made by the ld AO are contrary each

Sampat Lal Lodha, Nathdwara vs. ITO, Ward-2, Rajsamand

In the result, both appeals of the assessee are allowed

ITA 1/JODH/2022[2010-11]Status: DisposedITAT Jodhpur02 Aug 2023AY 2010-11
Section 143(1)Section 147Section 68

Date of Judgement/Order : 03/12/2021, held as under: - “The principles governing cash credit under Section 68 of the Act cannot be extended to unexplained investments under Section 69A of the Act.” iii] In view of above the reasons for reopening assigned and addition made by the ld AO are contrary each

DCIT Central Circle-07, Delhi vs. Anoop Soni, Delhi

In the result, the appeals of the assessee are partly allowed and the appeals of the Revenue are dismissed

ITA 157/DEL/2022[2017-18]Status: DisposedITAT Delhi02 Aug 2023AY 2017-18

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Hiren Mehta, CA &For Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 153ASection 69

case the CIT (A) was not Justified in upholding addition of Rs.11,70,000/- out of total addition of Rs.1,72,92,951/- as unexplained investments u/s 69 of the I.T. Act. 3. That on the facts and circumstances of the case and in law, the CIT (A) erred ... upholding addition of Rs.92,67,812/- out of total addition of ITA Nos. 156 & 157/Del/2022 Anoop Kumar Soni Rs.9,32,78,397/- as unexplained investments u/s 69 of the I.T. Act. 3. That on the facts and circumstances of the case and in law, the CIT (A) erred

DCIT, Central Circle-07, Delhi vs. Anoop Soni, Delhi

In the result, the appeals of the assessee are partly allowed and the appeals of the Revenue are dismissed

ITA 156/DEL/2022[2016-17]Status: DisposedITAT Delhi02 Aug 2023AY 2016-17

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Hiren Mehta, CA &For Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 153ASection 69

case the CIT (A) was not Justified in upholding addition of Rs.11,70,000/- out of total addition of Rs.1,72,92,951/- as unexplained investments u/s 69 of the I.T. Act. 3. That on the facts and circumstances of the case and in law, the CIT (A) erred ... upholding addition of Rs.92,67,812/- out of total addition of ITA Nos. 156 & 157/Del/2022 Anoop Kumar Soni Rs.9,32,78,397/- as unexplained investments u/s 69 of the I.T. Act. 3. That on the facts and circumstances of the case and in law, the CIT (A) erred

Anoop Kumar Soni, Delhi vs. DCIT, CC-7, New Delhi

In the result, the appeals of the assessee are partly allowed and the appeals of the Revenue are dismissed

ITA 1643/DEL/2021[2017-18]Status: DisposedITAT Delhi02 Aug 2023AY 2017-18

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Hiren Mehta, CA &For Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 153ASection 69

case the CIT (A) was not Justified in upholding addition of Rs.11,70,000/- out of total addition of Rs.1,72,92,951/- as unexplained investments u/s 69 of the I.T. Act. 3. That on the facts and circumstances of the case and in law, the CIT (A) erred ... upholding addition of Rs.92,67,812/- out of total addition of ITA Nos. 156 & 157/Del/2022 Anoop Kumar Soni Rs.9,32,78,397/- as unexplained investments u/s 69 of the I.T. Act. 3. That on the facts and circumstances of the case and in law, the CIT (A) erred

Anoop Kumar Soni, Delhi vs. DCIT, CC-7, Delhi

In the result, the appeals of the assessee are partly allowed and the appeals of the Revenue are dismissed

ITA 1642/DEL/2021[2016-17]Status: DisposedITAT Delhi02 Aug 2023AY 2016-17

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Hiren Mehta, CA &For Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 153ASection 69

case the CIT (A) was not Justified in upholding addition of Rs.11,70,000/- out of total addition of Rs.1,72,92,951/- as unexplained investments u/s 69 of the I.T. Act. 3. That on the facts and circumstances of the case and in law, the CIT (A) erred ... upholding addition of Rs.92,67,812/- out of total addition of ITA Nos. 156 & 157/Del/2022 Anoop Kumar Soni Rs.9,32,78,397/- as unexplained investments u/s 69 of the I.T. Act. 3. That on the facts and circumstances of the case and in law, the CIT (A) erred

Anoop Kumar Soni, Delhi vs. DCIT, CC-7, Delhi

In the result, the appeals of the assessee are partly allowed and the appeals of the Revenue are dismissed

ITA 1641/DEL/2021[2015-16]Status: DisposedITAT Delhi02 Aug 2023AY 2015-16

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Hiren Mehta, CA &For Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 153ASection 69

case the CIT (A) was not Justified in upholding addition of Rs.11,70,000/- out of total addition of Rs.1,72,92,951/- as unexplained investments u/s 69 of the I.T. Act. 3. That on the facts and circumstances of the case and in law, the CIT (A) erred ... upholding addition of Rs.92,67,812/- out of total addition of ITA Nos. 156 & 157/Del/2022 Anoop Kumar Soni Rs.9,32,78,397/- as unexplained investments u/s 69 of the I.T. Act. 3. That on the facts and circumstances of the case and in law, the CIT (A) erred

Anil Manhare, Durg vs. Income Tax Officer-2(1), Bhilai, Durg

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 152/RPR/2022[2012-13]Status: DisposedITAT Raipur02 Aug 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.152/Rpr/2022 "नधा"रण वष" / Assessment Year : 2012-13

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Ram Tiwari, Sr. DR
Section 147Section 148Section 269SSection 271D

cash loan of Rs.1,60,000/- that was raised by him from Shri Subhash Mohite (supra) and had held the same as his unexplained investment, then there was no justification for the department to infer that the assessee had raised any such cash loan from the aforementioned person. Once

Shree Murlidhar Jewellers, Jamnagar vs. The Pr.CIT-IV, Jamnagar

In the result, the appeal of the assessee is allowed

ITA 27/RJT/2020[2016-17]Status: DisposedITAT Rajkot02 Aug 2023AY 2016-17

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2016-17 Shree Murlidharjewellers Vs. The Pr.Cit-4 Chandi Bazar Jamnagar. Jamnagar 361 001. Pan : Aaifs 4781 N अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assesseeby : Shri D.M. Rindani, Ar Revenue By : Shri Shramdeep Sinha, Ld.Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 17/05/2023 घोषणा क" तार"ख /Date Of Pronouncement: 02/08/2023 आदेश/O R D E R Per Annapurna Guptapresent Appeal Has Been Filed By The Assessee Against Order Passed By The Ld.Pr.Commissioner Of Income-Tax)-4, Jamnagar [Hereinafter Referred To As “Ld.Pr.Cit)”] Dated 11.12.2019In Exercise Of His Revisionary Power Under Section 263 Of The Income Tax Act , 1961 ("The Act" For Short) Over The Assessment Order Passed U/S 143(3) Of The Act Pertaining To Asst.Year 2016-17. 2. The Assessee Has Raised The Following Grounds Before Us: I) The Learned Principal Commissioner Of Income-Tax - 4, Jamnagar Erred In Assuming Jurisdiction U/S 263 Of The Act, Particularly In The Light Of Reasons Stated By Him In The Show Cause Notice & In The Order Passed U/S 263 Of The Act & Hence The Impugned Order Is Bad In Law. 2 Ii) The Learned Principal Commissioner Of Income-Tax - 4, Jamnagar Erred In Directing The Assessing Officer To Make Addition Of Rs. 70,89,098/- U/S 69 Of The Act By Failing To Appreciate That Provisions Of Section 69 Were Not Attracted In.”

For Appellant: Shri D.M. Rindani, ARFor Respondent: Shri Shramdeep Sinha, ld.CIT-DR
Section 115BSection 143(3)Section 263Section 69

business income and allowing set off expenses against the same, while, as per the ld.Pr.CIT, the same ought to have been treated as unexplained investment and subjected to tax ,without setting off any expenses, at the rate prescribed u/s 115BBE of the Act. 4. Para-2 of the ld.Pr.CIT ... source of such investment in stock, the surrendered stock could not be treated as part of business but was to be treated as unexplained investment u/s 69 of the Act and further was to be taxed at the rates prescribed u/s 115BBE of the Act. He directed

Bridge India Fund, New Delhi vs. ACIT (Int Tax) Circle-1(3)(2), Mumbai

In the result ITA number 457/M/2023 for assessment year 2014 – 15 is partly allowed for statistical purposes

ITA 458/MUM/2023[2015-16]Status: DisposedITAT Mumbai01 Aug 2023AY 2015-16

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri S. Krishnan, ARFor Respondent: Shri Soumendu Kumar Das, DR
Section 142(1)Section 144Section 147

erred in holding the purchase value of 12,00,840 shares of Odyssey, amounting to Rs.15,70,60,202/- to be unexplained investment within the meaning of section 69 of the Act, despite the fact that: a. No investment of this nature stands made in FY 2013-14 relating ... cause notice to the assessee to hold that why the value of the purchase amount of ₹ 157,060,202 should not be held as unexplained investment under section 69 of The Income Tax Act and further why not to tax commission on fictitious trade incurred by the assessee

Bridge India Fund, New Delhi vs. ACIT (Int Tax) Circle-1(3)(2), Mumbai

In the result ITA number 457/M/2023 for assessment year 2014 – 15 is partly allowed for statistical purposes

ITA 457/MUM/2023[2014-15]Status: DisposedITAT Mumbai01 Aug 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri S. Krishnan, ARFor Respondent: Shri Soumendu Kumar Das, DR
Section 142(1)Section 144Section 147

erred in holding the purchase value of 12,00,840 shares of Odyssey, amounting to Rs.15,70,60,202/- to be unexplained investment within the meaning of section 69 of the Act, despite the fact that: a. No investment of this nature stands made in FY 2013-14 relating ... cause notice to the assessee to hold that why the value of the purchase amount of ₹ 157,060,202 should not be held as unexplained investment under section 69 of The Income Tax Act and further why not to tax commission on fictitious trade incurred by the assessee

The Dy. Commissioner of Income Tax, Central Circle-6(4), Mumbai vs. Shri Narendra Gehlaut, Mumbai

In the result, the appeal filed by the Revenue is partly allowed e appeal filed by the Revenue is partly allowed for statistical purposes

ITA 1101/MUM/2022[2017-18]Status: DisposedITAT Mumbai31 Jul 2023AY 2017-18

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2017-18 The Dy. Cit, Central Circle-6(4), Shri Narendra Gehlaut, Room No. 1925, 19Th Floor, Air 875, Sector – 17B, Gurgaon, India Building, Nariman Point, Vs. Haryana, 122 001. Mumbai-400021. Pan No. Aazpg 9630 K Appellant Respondent

For Appellant: Mr. K. GopalFor Respondent: Mr. Jasdeep Singh, CIT-DR

deleting the addition of Rs 11,53,38,145/ the addition of Rs 11,53,38,145/- on account of on account of unexplained investment w/s 69B of the Act by unexplained investment w/s 69B of the Act by unexplained investment w/s 69B of the Act by observing that ... Assessing Officer as not recorded in the books of accounts recorded in the books of accounts and assessed as and assessed as unexplained investment within the meaning of section 69B of the Act. investment within the meaning of section 69B of the Act. investment within the meaning of section

DCIT, Central Circle- 26, New Delhi vs. Aruna Chaudhary, New Delhi

ITA 581/DEL/2020[2008-09]Status: DisposedITAT Delhi31 Jul 2023AY 2008-09

Bench: Sh. M. Balaganesh & Sh.Anubhav Sharma

Section 147Section 153A

favour of the assessee on the basis of the earlier order dated 09.03.2018 of Ld. CIT(A)-29 (supra) where addition on account of unexplained investment in the purchase of said property was deleted. 7. In the light of aforesaid as finality stands attached to said order dated 09.03.2018, holding

Dy. Commissioner of Income Tax, CC-Vapi, Vapi vs. Dharmesh Bharatbhai Thakkar, Valsad

In the result, appeal filed by the Revenue is dismissed

ITA 287/SRT/2022[2017-18]Status: DisposedITAT Surat31 Jul 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.287/Srt/2022 "नधा"रण वष"/Assessment Year: (2017-18) (Virtual Hearing) The Dcit, Central Circle, Vs. Dharmesh Bharatbhai Thakkar, Vapi 402, Amar Chambers, Opp. Lal School, Station Road, Valsad – 396001. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aarpt2933Q Appellant By Shri Ashok B. Koli, Cit(Dr) Respondent By Shri Hardik Vora, Advocate 27/06/2023 Date Of Hearing Date Of Pronouncement 31/07/2023

Section 143(3)Section 250(4)Section 69

Ld.CIT(A) has erred in deleting the addition of Rs.6,31,50,000/- made by the Assessing Officer on account of unexplained investment u/s 69 of the I.T. Act. (2) On the facts and in the circumstances of the case and in law, the Ld.CIT(A) has erred in deleting ... addition of Rs.6,31,50,000/- made by the Assessing Officer on account of unexplained investment u/s 69 287/SRT/2022/AY.2017-18 Dharmesh B. Thakkar of the I.T. Act ignoring the fact that the addition was made on the basis of incriminating documents in the form of notarized agreement found and impounded during

Ravi Mahexa, Daman and Diu vs. Income Tax Officer, Daman Ward, Daman

ITA 195/SRT/2022[2017-18]Status: DisposedITAT Surat31 Jul 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

Section 115BSection 143(3)Section 145(3)Section 40ASection 68

195/SRT/2022 Ravi Mahexa confirming the action of assessing officer in making the addition of Rs.4,31,479/- on account of alleged unexplained investment to the fixed assets.” (v) Ground No.5 raised by the assessee, in ITA No. 194/SRT/2022, is as follows: “On the facts on the facts and circumstances ... Income Tax (Appeals) has erred in confirming the action of assessing officer in making the addition of Rs.4,31,479/- on account of alleged unexplained investment to the fixed assets.” 55. Succinct facts qua the issue (facts as per ITA No.194/SRT/22) are that during the year under consideration, assessee

Ravi Mahexa, Daman and Diu vs. Income Tax Officer, Daman Ward, Daman

ITA 194/SRT/2022[2016-17]Status: DisposedITAT Surat31 Jul 2023AY 2016-17

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

Section 115BSection 143(3)Section 145(3)Section 40ASection 68

195/SRT/2022 Ravi Mahexa confirming the action of assessing officer in making the addition of Rs.4,31,479/- on account of alleged unexplained investment to the fixed assets.” (v) Ground No.5 raised by the assessee, in ITA No. 194/SRT/2022, is as follows: “On the facts on the facts and circumstances ... Income Tax (Appeals) has erred in confirming the action of assessing officer in making the addition of Rs.4,31,479/- on account of alleged unexplained investment to the fixed assets.” 55. Succinct facts qua the issue (facts as per ITA No.194/SRT/22) are that during the year under consideration, assessee